- 2 - petitioner’s 1990-92 tax liabilities. In that same notice respondent also rejected petitioner’s offer in compromise. On that same date respondent sent Mark Fowler and Joylyn Souter- Fowler (petitioners) a second Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330. In this notice respondent sustained the filing of a Federal tax lien with respect to petitioners’ 1994-96 tax liabilities, and respondent again rejected petitioners’ offer in compromise. Prior to these determinations, petitioners sought and were offered an Appeals hearing, but they did not attend due to personal reasons. One month after the scheduled hearing date, the Appeals officer issued the above determinations sustaining the filing of the Federal tax liens and rejecting petitioners’ offers in compromise. With respect to both determinations, petitioners appealed to this Court. The issue for consideration is whether respondent abused his discretion by rejecting petitioners’ offers in compromise and by sustaining the filing of the Federal tax liens.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011